Search - consideration

. … 2002-0169607 states that the "contribution sociale généralisée" and the "contribution pour le remboursement de la dette sociale" qualify as a non-business income tax … since these contributions have the legal characteristics of a tax (levied without direct consideration) as opposed to social contributions which, in turn, confer on those who pay them a right to benefits. … [S]ocial security contributions generally do not qualify as income or profits taxes because they are not really taxes at all, within the judicially accepted meaning of that term. ...

FA2 will transfer all of its shares of FA5 to New FA3 in consideration for shares of New FA3. ...

., the greatest of the FMV of the consideration given, the ACB of the policy and the CSV of the policy at the time of transfer. ...

Proposed transactions Bco will purchase Aco’s interest in Property 1 and Property 2 (being mining claims) in consideration for the reduction of the intercompany debt owing by Aco to Bco, with Aco including the proceeds of disposition in element F of the definition of “cumulative Canadian development expense.” ...

Proposed transactions Bco will purchase Aco’s interest in Property 1 and Property 2 (being mining claims) in consideration for the reduction of the intercompany debt owing by Aco to Bco, with Aco including the proceeds of disposition in element F of the definition of “cumulative Canadian development expense.” ...

The redemption price of the shares, which were short-term preferred shares, was set at the fair market value of the assets (transferred on a rollover basis to Subco) in consideration for which they were issued, which originally had been set at an amount of $2M, but was subsequently reduced by agreement with CRA and pursuant to a price adjustment clause to $1M. ...

The redemption price of the shares, which were short-term preferred shares, was set at the fair market value of the assets (transferred on a rollover basis to Subco) in consideration for which they were issued, which originally had been set at an amount of $2M, but was subsequently reduced by agreement with CRA and pursuant to a price adjustment clause to $1M. ...

After acquiring A’s Holdco common shares for FMV consideration ($0.5M in notes issued by them to A), A’s children then sold those shares to a Newco formed by them in exchange for a Newco promissory note for $0.5M. ...

After acquiring A’s Holdco common shares for FMV consideration ($0.5M in notes issued by them to A), A’s children then sold those shares to a Newco formed by them in exchange for a Newco promissory note for $0.5M. ...

For the purposes of Part XIII withholding and section 116, any amount paid or credited by a payer to the Canadian Sub-custodian in respect of the property held by the Subfund on behalf of the Pension Fund, including purchase consideration for such property, will be considered an amount paid or credited to the Pension Fund in proportion to its participation in the assets and income of the particular Subfund. ...